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Earthjustice & Sierra Club | Rhetoric vs. Reality

RHETORIC VS. REALITY: The Myth of “Renewable Natural ” for Building Decarbonization

1 Earthjustice & Sierra Club | Rhetoric vs. Reality

JULY 2020

Sasan Saadat, Earthjustice’s Right to Zero campaign Matt Vespa, Earthjustice’s Right to Zero campaign Mark Kresowik, Sierra Club

2 EXECUTIVE SUMMARY

Policymakers seeking to cut emissions and reduce reliance on fossil are increasingly examining use within buildings, which account for nearly 40% of emissions globally. One of the largest drivers of these emissions is the burning of fossil fuels like gas for home heating, hot water, and . In 2018, carbon emissions from U.S. buildings increased 10% due to growth in these uses alone.1

There is growing consensus that electrifying buildings – using electric appliances like and induction stoves to replace the need for – is the clearest path to mitigating their . Efficient, all-electric buildings eliminate on-site carbon emissions and leakage, and they can eventually achieve net-zero emissions as the grid becomes cleaner. Furthermore, building eliminates the health impacts from burning gas indoors,2 and reduces the safety hazards from gas and , all while capitalizing on the declining costs of generating from solar and .

Numerous studies indicate that electrification is the lowest-risk and lowest-cost method to reduce gas emissions (“GHGs”) from buildings, while generating additional societal benefits. And because buildings last for many decades, avoiding gas infrastructure and appliances in new construction is crucial for avoiding lock-in of reliance. As such, many policymakers across the U.S. and globally see electrification as the future of buildings. By early 2020, more than 30 and counties in the U.S. passed policies requiring or supporting all-electric new construction.

Gas , which rely on maintaining and expanding fuel delivery infrastructure to buildings to generate revenue, view electrification as an existential crisis. The ’s response has been to pitch fossil gas alternatives (“FGAs”) – often marketed as “renewable” (“RNG”) – as an alternative to building electrification.

The argument goes that existing gas infrastructure can continue to operate by replacing today’s fuel with a range of biologically and synthetically derived non-fossil gaseous fuels.

This report examines the potential for FGAs to decarbonize buildings and refutes the claim that FGAs are a viable alternative to building electrification. 1 EarthjusticeEarthjustice & & Sierra Sierra Club Club | | Rhetoric Rhetoric vs. vs. Reality Reality

Topline findings include:

• The potential supply of FGAs is a small fraction of gas demand. The gas industry’s own research found that after two decades of ramping up supply and production, FGAs could only replace 13% of the existing demand for fossil gas. Any strategy to reduce building emissions that relies on FGAs in lieu of electrification would not to complete decarbonization and diverts limited FGA supplies from more difficult to electrify sectors.

• Replacing fossil gas with FGAs is extremely costly. High production costs mean FGAs range from 4 to 17 times more expensive than fossil gas.

• FGAs have a mixed environmental record. Facilities where FGAs are produced can exacerbate air and impacts in nearby communities. When methane is intentionally produced, leakage throughout the distribution process can result in increased emissions.

• FGAs perpetuate the health impacts of combustion. Burning FGAs in homes, offices, and commercial spaces has the same issues inherent to any combustion-based fuels: they produce toxins that harm the health of people living, working, or learning in these buildings and also contribute to local through continued emissions of NOx and other combustion byproducts.

CLEAN ALL-ELECTRIC HOUSE GAS-BURNING HOUSE

Local clean energy jobs Clean air Powered by gas Methane leakage Health and safety benefits Health and safety risks Indoor and outdoor Saves money and energy energy air pollution

Through electrification, decarbonizing our buildings is also an opportunity to reduce legacy sources of indoor air pollution.

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The report finds that due to the limited An internal set of AGA meeting notes from supply and high cost of and March 2018 shows the industry determined synthetic gas, and the associated pollution FGAs can be used to “mitigate the and health impacts, the small and costly opposition’s fervor” to phase out the burning amount of FGAs available should be used to of gas due to concerns.4 decarbonize sectors where there are few or no lower-cost mitigation solutions. Buildings Another internal document makes clear do not meet these criteria. an awareness of FGAs’ limits, coming from an industry source: “[In my opinion], RNG Nevertheless, gas system incumbents will not sustain our industry at its present are embarking on a coordinated strategy size.”5 In another instance, a board member advocating for the use of FGAs in homes for a gas industry advocacy group told and buildings, irrespective of the fact that on the record: “Dairy biogas low-grade building heat is a poor use case is way too expensive” to use in home or for the limited supply of high-cost, low- – five to 10 times more expensive carbon FGAs. than fossil gas. “It doesn’t pencil out and it doesn’t make all that much sense from an The second half of the report looks at environmental standpoint. It’s a dream.”6 both gas industry incumbents’ efforts to fight electrification through a well-funded We find a pattern of talking points and campaign to sway public opinion – often lobbying efforts that leverage FGAs as a through fake grassroots organizations – means of maintaining a gas-based heating and their misleading public rhetoric on the system and stalling the transition away from potential use of FGAs as an alternative fossil fuels. building electrification. This is not unfamiliar territory: The tactics Claims from utilities like Southern come from the same Gas Company (“SoCalGas”) that replacing playbooks that have dismissed and 20% of fossil gas with FGAs can have the obfuscated the threat of . same impact as electrification, or Dominion In this case, the widespread adoption of a Energy, that replacing 4% of fossil gas can proven and cost-effective means of fighting eliminate the entire of its climate change is being attacked and gas operations, are flawed and misleading stalled in order to protect fossil fuel financial given the limited supply of low-carbon FGAs. interests.

These statements positioning FGAs as a Ultimately, FGAs do not provide a path to clean source of energy make more sense decarbonizing the gas grid in line with a net- when reviewing internal gas industry zero emissions . Policymakers documents. The American Gas Association’s must see beyond the gas industry’s rhetoric (“AGA”) Clean Energy Task Force developed around FGAs and acknowledge the reality draft policy principles stating the AGA of their high costs, limited supply, and “supports policies that define the term environmental risk. ■ ‘renewable energy’ to include RNG on par with other energy sources, such as energy generated from wind or solar resources.”3

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PART 1: The appropriate – and limited – role for lower-carbon gas alternatives on the road to decarbonization

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Climate goals require 1. a gas phaseout

To keep global average from A 2019 study expanded the analysis to rising above 1.5°C and avoid the worst include leakage in distribution and end- impacts of climate destabilization, the uses, and found observed emissions from world must achieve net-zero emissions of local gas distribution to be a factor of two greenhouse by mid-century.7 This to three times larger than those in the U.S. requires us to stop burning fossil fuels as EPA’s inventory.13 Researchers in California rapidly as .8 Thus, greenhouse found average home leakage rates to gas emissions from unabated gas use be 0.5%, representing leaks “an order of are incompatible with achieving net-zero magnitude larger” than earlier estimates.14 emissions.9 Even aiming for the far less safe 2°C warming scenario would mean keeping Importantly, methane leakage issues more than half of the world’s existing gas are not limited to fossil gas. Whether the reserves unused and unburned.10 methane is synthetic, biogenic, or fracked, if it’s pumped into homes through the existing Achieving a net-zero emissions society distribution network, it will face similar inevitably means a substantial decline in leakage rates, and ultimately have the same gas consumption. With gas overtaking negative climate impact from methane as the largest source of fossil fuel emissions leakage into the atmosphere. in the , greater focus has been given to its true climate impact.

A growing body of research has highlighted the high of Whether the methane methane, the main constituent of gas. is synthetic, biogenic, Methane’s radiative force,11 which is 36 times or fracked, if it’s more potent than CO2, and its pervasive leakage along the gas supply chain – both pumped into homes of which are proving more severe than through the existing previously understood – increase the distribution network, urgency of its near-term mitigation. it will face similar New findings suggest methane leakage leakage rates, and throughout the nation’s gas delivery system ultimately have the is much more widespread than officials understood just a few years ago. In 2018, same negative climate research published in the journal Science impact from methane found the leakage rate in the U.S. gas supply chain equaled 2.3% of U.S. gross leakage into the gas production, 60% higher than the EPA’s atmosphere. official estimate.12

Gas flare at Permian Basin— Eddy County, NM blake.thornberry, Flickr, CC BY-NC-ND 2.0

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Different sources of fossil 2. gas alternatives

The term “RNG” is currently used as an umbrella term to describe a range of fossil gas alternatives, most of which fall into two categories: biogas and synthetic gas. Different feedstocks and production methods for either of these alternatives require trade-offs around cost, supply, and social and ecological impact.15

BIOGAS

Biogas refers to methane derived from organic sources, such as or animal . It is produced via two main pathways, and thermal . When upgraded and conditioned so it is pipeline-ready, biogas is typically referred to as biomethane.

ANAEROBIC DIGESTION THERMAL GASIFICATION

Anaerobic digestion is the Thermal gasification breaks down dry in decomposition of wet, organic a high-heat environment, creating methane from matter by in an solid matter where none would ordinarily occur. -free environment. Often, The feedstocks used in this process are mostly anaerobic digestion is used to lignocellulosic – so named because they produce biogas from sources which contain carbon-based polymers – which include: currently emit methane, including: • agricultural residues, such as the unusable • gas; portions of stalks, stems, and branches; • animal manure from • and forest residues, such as livestock operations; sawmill residue and the extraneous wood • wastewater treatment plants generated from logging; (“WWTP”); and • energy crops, grown specifically for • organic municipal solid the purpose of becoming fuel, such as (“MSW”), specifically perennial grasses; and waste. • inorganic components of MSW, such as construction debris, such as , , and .

Lignocellulosic biomass can also be used as a non-gaseous fuel, such as conversion into renewable diesel. While gasification is a well-understood process, thermal gasification of biomass has not yet been proven at scale.

6 Earthjustice & Sierra Club | Rhetoric vs. Reality Lima Synthetic Gas Research Center Ohio Development Services Agency, Flickr, CC BY 2.0

SYNTHETIC GAS

Synthetic gas is produced by converting electricity into a gaseous fuel through a process called power-to-gas, or P2G. It begins with electrolysis – using electricity to split water into and oxygen. Hydrogen itself is a gaseous , but to match the chemical make-up of fossil gas, it must go through a second step called methanation where is added to the hydrogen.

When powered by renewable electricity, this process allows power from sources such as wind or solar to be converted into a gaseous fuel that can be carried by traditional pipelines.

But the substantial amounts of energy and conversion loss needed to turn electricity into hydrogen, and then hydrogen into synthetic methane, wastes much of the renewable power. After electrolysis, only about 67% to 81% of the initial energy remains. Not including the energy required to capture the CO2, the methanation process leaves only about 54% to 67% of the energy.16 All else being equal, using renewable electricity to power electrolysis and create synthetic methane that is then used to generate heat is far more costly and energy-intensive than the direct use of renewable electricity through heat pumps.

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Not all fossil gas alternatives 3. are environmentally beneficial

While estimates for the maximum amount Biogas from CAFOs of technically producible FGAs vary, these estimates rarely screen for those Methane generated from the anaerobic decomposition FGAs which are actually environmentally of manure in lagoons at concentrated animal feeding beneficial to use. Higher potential volumes operations (“CAFOs”) has been advanced as a of FGAs should not be assumed to be promising source of biomethane production. While often marketed as “sustainable,” biomethane capture does more environmentally beneficial. Because not abate the significant harms CAFOs have on already of methane’s severe radiative force and overburdened local communities and ecosystems. For the high probability of leakage throughout example, dairy CAFOs in the Southern San Joaquin its lifecycle, generating new sources of Valley of California are the region’s largest source of methane where none would ordinarily occur -forming volatile organic compounds (“VOC”) and can lead to an overall increase in GHGs. further damage air quality through significant emissions of and fine particulate matter.i These facilities A new analysis by the Natural Resources also contribute to nitrate pollution of drinking water and Defense Council estimates that screening contaminate waterways, with runoff leading out ecologically problematic sources of to the eutrophication of and streams.II Every FGAs would exclude roughly half the total well monitored near dairies in the Central Valley Dairy amount of FGAs technically producible.17 Representative Monitoring Program showed nitrate levels above the maximum contamination limit.iii Recent research highlights the potential In addition, while proponents assert that methane from for intentionally produced methane to CAFOs manure lagoons would otherwise be emitted into create climatically significant levels of the atmosphere, these emissions are not an inevitable leakage.18 The analysis shows that FGAs or ordinarily occurring consequence of raising livestock. “from intentionally produced methane is They are the result of industrial livestock management always GHG positive unless total system decisions (namely confinement, concentration, and liquid- based manure storage)iv and a regulatory environment leakage is 0.”19 At leakage levels observed that permits these practices to continue despite their significant air and water quality impacts. Were herd sizes maintained at more manageable levels, livestock operations could avoid producing waste in excess of agronomic rates for nearby crops, maintain pasture- based livestock operations, or more feasibly employ dry handling storage systems, thereby avoiding these in the first instance.v Because the high capital costs of anaerobic digesters make economic sense only for the CAFOs that produce and store large quantities of wet manure, markets and subsidies for biomethane capture reward the largest and most polluting CAFOs, reinforcing and intensifying trends of industry consolidation, with corresponding increases to localized pollution.vi

Dairy on a hot summer day in Bakersfield, CA David McNew/Getty Images 8 Earthjustice & Sierra Club | Rhetoric vs. Reality in the existing biogas industry, intentionally In particular, mitigation strategies that produced methane, even from climate- address the underlying causes of waste neutral CO2 sources, has substantial climate methane are important to consider when impacts.20 Thus, the climate benefit of FGAs these practices are associated with multiple depends on whether they are derived from social and environmental harms. Markets methane that would otherwise be emitted that value pollution may become obstacles into the atmosphere. Of the total to policies that can reform inefficient of FGAs technically producible, only a very and polluting practices or which may small portion comes from methane already appropriately make polluters responsible being emitted to the atmosphere. The study for addressing their own emissions. In the estimates that capturable waste methane graphic below, we illustrate a framework for (e.g., from uncontrolled and assessing whether FGAs are actually likely to wastewater treatment plants) is less than be environmentally beneficial. The supply of 1% of current gas demand.21 The rest must FGAs from genuine and unavoidable waste be intentionally produced and will pose the methane is far more limited than the amount risk of additional methane leakage that can that is technically producible. offset any potential emission reductions.

Even FGAs that can be produced from methane already emitted into the atmosphere should not automatically be considered environmentally beneficial. As A premium should be a general rule, proposals to commoditize placed on mitigation pollution should be treated with caution. strategies that Climate “solutions” that perpetuate or exacerbate local pollution are incompatible permanently avoid the with the principles of a just and equitable generation of methane transition. In fact, creating markets for emissions through FGAs that capture methane pollution can perversely incentivize continued reliance on more sustainable practices that lead to the methane pollution practices. in the first instance. As researchers note, “because biogas and biomethane can generate revenue, it is not only possible but expected to intervene in biological systems to increase methane production beyond what would have happened anyway when there is an incentive to do so.”22 Before considering capturing and using waste methane as an FGA, decision makers should examine whether the methane emissions could be prevented in the first place through better resource or practices. A premium should be placed on mitigation strategies that permanently avoid the generation of methane emissions through more sustainable practices.

9 EarthjusticeEarthjustice & & Sierra Sierra Club Club | | Rhetoric Rhetoric vs. vs. Reality Reality

What Biomethane Sources are Environmentally Suitable?

The supply of biomethane that is environmentally beneficial to produce Maximum biomethane that is is substantially smaller than the total maximum potential of biomethane. technically producible Genuine waste methane which cannot be readily avoided and has few other social or environmental harms (e.g., wastewater treatment) may be environmentally beneficial to capture and reuse as biomethane.

Does production require generating new sources of methane where none would AVOID ordinarily occur? YES Thermal Gasification of: • Energy crops • Forest product residue* • Usable agricultural residue* NO

RATIONALE Due to methane’s severe radiative WHAT’S LEFT: force, and the high probability of leakage throughout its lifecycle, it Biomethane from sources of is preferable to avoid generating fugitive methane emissions new sources of methane where none would ordinarily occur.

AVOID Can methane emissions be Anaerobic Digestion of: prevented through alternative YES • Manure from CAFOs resource and waste management? • Preventable, rescuable or compostable food waste

NO RATIONALE A premium should be placed on mitigation strategies that WHAT’S LEFT: permanently avoid the generation Biomethane where capture- of emissions in the first instance. and-use is the optimal Biomethane production from these sources can perversely perpetuate mitigation strategy poor resource management.

* While they do not ordinarily generate methane, certain types of from agricultural or (e.g., sawmill residue) may be unpreventable and difficult to or divert toward other uses. If no superior waste prevention or management strategy exists, it may be environmentally advantageous to redirect these waste streams toward fuel production. Nonetheless, it may be practical to exclude these from estimates of biomethane potential since multiple end-uses beyond current gas demand will compete for the limited supply of sustainable lignocellulosic biomass. Potential renewable fuel sources are generally better devoted to liquid fuels that displace more expensive, GHG-intensive or to which does not pose the risks of GHG increases from methane leakage or emit when combusted.

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Fossil gas alternatives have no 4. clear path to fully decarbonizing the gas grid

Even the gas industry’s own analysis finds there is an insufficient supply of carbon-free gas to meet anything more than a small portion of current gas demand. According to a study by the American Gas Foundation (“AGF”), even after fully ramping up the production of renewable gas, FGAs could supply between just 6% to 13% of current gas demand,23 clearly falling short of the goal of net-zero emissions and requiring fossil gas to make up the difference.

In the AGF study, a proposed high-resource scenario, which would still meet just 13% of U.S. gas demand, relies on significantly increased thermal gasification of energy crops, accelerating production from 123 to 837 tBtu/year (trillion British thermal units a year, a measure of gas production). Expanding reliance on purpose-grown energy crops would introduce serious risks by diverting from food to energy production. It could drive up the cost of food and drive changes in land-use patterns that would transform forests and – natural carbon sinks – into agricultural areas for energy crops. According to the U.S. EPA’s own assessment, the Renewable Fuel Standard – an existing program that incentivizes production – has resulted in the conversion of 4 to 8 million acres of land, completely nullifying and overwhelming any climate benefit the program might have had.24 Thus, additional incentives are likely to result in a dramatic loss of stored carbon and increased emissions that can make even more GHG-intensive than fossil fuels.

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A limited amount of biogas (363-876 tBtu/year) could come from the residual portions of agricultural and forest products that are not traditionally usable. But some of these forest and crop residues would be more ecologically advantageous to devote to other purposes besides fuel production, such as animal feed or incorporation as a soil amendment into compost. The high-resource scenario also assumes that most or all forest and crop residue would be devoted exclusively to gaseous fuel production as opposed to liquid fuels or power generation, more suitable uses explored later in this report.

Even the most aggressive scenario laid out by the AGF still reflects what would be possible by 2040, after two decades of scaling FGA potential. Mobilizing all these resources toward existing gas demand, which still would only meet 13% of the nation’s gas needs, would leave a far smaller amount of biogas and synthetic gas available for more difficult to decarbonize end uses.

FGA RESOURCE POTENTIAL AND CURRENT GAS DEMAND

30,000 31,000

25,000

20,000

15,000

10,000 TOTAL VOLUME ( tBtu /Y) VOLUME TOTAL

5,000 4512.6 1913.2 220 240 0 2018 GAS LOW (2025) HIGH (2025) LOW (2040) HIGH (2040) DEMAND*

Source: American Gas Foundation RNG Report, Dec. 2019 * U.S. Energy Information Administration 1212 Earthjustice & Sierra Club | Rhetoric vs. Reality

Low-carbon gases are 5. significantly more expensive than fossil gas

Relative to the cost of fossil gas, FGAs are produce hydrogen and avoid the additional far more expensive to produce. Between step of methanation. But hydrogen can only 2018 and 2020, fossil gas mostly be injected into existing gas pipelines at hovered between $2.03-$2.86/MMBtu minimal volumes before risking dangerous (one million British Thermal Units).25 By levels of corrosion. Optimistic scenarios contrast, the AGF’s estimates for landfill estimate that the pipeline system could gas, typically the cheapest way to produce handle volumes of 7% hydrogen by energy biogas, range between $10-$20/MMBtu.26 content before requiring costly upgrades.29 Dairy manure projects are projected to cost closer to $40/MMBtu. Thermal gasification Thus, each FGAs decarbonization projects, necessary to achieve higher potential for building end uses is limited technical potentials, all begin at even higher by supply, cost, or environmental integrity. production costs.27 Synthetic methane is disadvantaged by its conversion inefficiencies and high costs. The AGF concluded that by 2040, half Biogas, which is limited in supply, could of all low-carbon, non-fossil gas used only be made in more substantial amounts in their aggressive resource potential by accepting significant environmental scenario could be available at $20/MMBtu. risks and higher production costs. While While some low-cost biomethane from hydrogen production is compatible with landfills and wastewater treatment plants net-zero emissions and technically unlimited is available, the costs rapidly increase as in supply, its suitability for decarbonizing production is expanded and pushed to more the existing gas grid are constrained by its challenging projects. effects on the pipeline.30

A report for the California Energy Commission similarly finds: “[e]ven under optimistic cost assumptions, the blended costs of hydrogen and synthetic natural gas are found to be 8 to 17 times more expensive than the expected trajectory of natural gas.”28 While substantial cost declines are likely to be a decade or more away, synthetic gas from hydrogen (whereby hydrogen is produced from electrolysis and then methanated) is estimated to remain many times more expensive than fossil fuels for decades to come, even assuming aggressive and rapid industry learning. Production costs would be lower if electrolysis is used only to

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Given their limited supply and high 6. costs, fossil gas alternatives are best-suited for use in harder-to- decarbonize segments of society

Injecting FGAs into the gas delivery system hits a dead end well short of complete decarbonization. Even outstanding HOW DO HEAT improvements to the production costs of FGAs are unlikely to alter a fundamental point: Decarbonized gas is better PUMPS ? suited for applications that currently lack a low-cost By transferring heat rather than creating it, heat pumps deliver hot pathway to direct electrification. water 3-5 times more efficiently than conventional water heaters. Even if renewable energy costs decrease and electrolyzer Heat pulls warmth technology improves, lowering the cost of renewable from the air. hydrogen and using renewable synthetic gas to decarbonize Warm air is compressed, heating will likely remain far more expensive than running increasing its temperature. heat pumps on renewable power, an existing and already Condenser coils transfer widely available technology. Changes to this dynamic are heat to the water. limited by basic physics: Using renewable electricity to power electrolysis for the production of gas will result in significant conversion losses. To produce 100% renewable Cool Air Out Hot Water Out hydrogen, an electrolyzer has to have access to 3 to 3.5 times its installed capacity of solar or wind generation.31 Because of this inherent inefficiency, P2G will always Warm be considerably more expensive than directly using Air In electricity.32 On top of that, gas-burning appliances such as and are far less efficient than heat pumps. Direct electrification is therefore far more effective in decarbonizing heat wherever it is possible to use heat pumps. Even for many industrial uses, which require Pump Heat between 75 to 140°C, heat pumps are the most effective option.33

Given the limited availability of economic, sustainable FGAs, their role in a net-zero energy system will necessarily be small. Dedicating FGAs to incrementally lower the carbon Tank Storage intensity of gas heating in buildings is a poor use case, especially given their potential to advance decarbonization Cool Water In in more challenging sectors.

On a cost-effectiveness basis, policymakers should focus on socially optimal use cases for liquid/gaseous , such as delivering high industrial heat for production or powering air or marine

14 Earthjustice & Sierra Club | Rhetoric vs. Reality transportation. Biogas and synthetic gas, as well as other renewable liquid fuels, have several advantages over electricity. Though Because heat pumps costly, limited, and inefficient to produce, and electric vehicles they are energy-dense, can be stored and transported more readily than electricity, and offer superior work with existing infrastructure that must efficiency and rely on combustion. In optimizing their use, eliminate end-use the advantages of renewable fuels (e.g., flexible, combustible, dispatchable) should air pollution, direct be weighed against their disadvantages use of electricity (e.g., cost, leakage, limited supply) and should be used to the availability of alternatives such as electrification and demand management. the maximum extent Because heat pumps and electric vehicles feasible in buildings offer superior efficiency and eliminate end- use air pollution, direct use of electricity and . should be used to the maximum extent feasible in buildings and transport.

SOME SUGGESTED USES FOR FGAs:

HIGH-HEAT DECARBONIZING FUEL FOR HEAVY INDUSTRIAL CHEMICAL ROAD, AIR, PRODUCTION PRODUCTION AND MARITIME TRANSPORTATION Certain carbon-intensive Hydrogen is required as , such a feedstock for industrial Renewable liquid or as steel production, require processes, such as gaseous fuels, either sustained temperatures ammonia and iron ore from biogenic materials greater than 200°C, which production. Nearly all of the or from power-to-gas/ are currently generated by hydrogen currently used power-to-liquid pathways, combusting natural gas. While to meet these demands is may eventually enable it’s possible to use advanced developed through Steam decarbonization of the heat pumps to deliver Methane Reformation heavier categories of high process heat in some (“SMR”) of fossil gas, transportation, such as instances, changing industry an emissions-intensive international air and operations to employ electricity process. Renewable transport. in place of combustion may hydrogen offers a way to require expensive logistical provide cleaner feedstocks changes and facility retrofits.34 to these industries. Biogas and synthetic gas could enable decarbonization of these sectors right now, without requiring costly modifications.

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Even with the current, low- Moreover, FGAs are not an ideal fuel costs of fossil gas, electrification proves source for buildings because, just like fossil to be a cost-effective energy solution gas, their combustion harms the health of for many households. The balance would people living, working, or learning in these significantly tilt in favor of electrification if buildings. They also contribute to local air FGAs were used given their extremely high pollution through continued emissions of costs. NOx and other combustion byproducts – an avoidable outcome, given the availability of These findings are not limited to warmer electric, zero-emission solutions. In addition, such as California. A multifaceted even after treatment for injection into gas analysis by Evolved Energy Research on pipelines, the potential residual of pathways to reducing the state of New biomethane has yet to be fully understood. Jersey’s emissions and meeting its 2050 A recent study by the California Energy climate goals included a “least cost” option. Commission found that using biomethane That scenario, along with numerous other for home appliances causes DNA damage options discussed, required buildings to be and mutagenicity, with varying results for 90% electric by 2030.35 fossil gas.36

Nevertheless, gas system incumbents The existential financial risks large-scale are embarking on a coordinated strategy electrification present to the incumbent advocating for the use of FGAs in homes fossil fuel industry – largely responsible for and buildings, irrespective of the fact that the energy and environmental challenges low-grade building heat is a poor use case we now face – should not be a reason to for the limited supply of high cost, low- waste precious time and resources and on carbon FGAs. promoting FGAs for use in buildings. ■

A father prepares a meal with his son on an induction stove. Children who grow up in a home with a are 42% more likely to develop asthma than those who don’t.37 Tom Werner/Getty Images 1616 Earthjustice & Sierra Club | Rhetoric vs. Reality

PART 2: How the reality of fossil gas alternatives differs from gas and industry rhetoric

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Fossil gas alternatives help 1. preserve the gas model in the face of electrification

Despite the inefficiency of FGAs laid out in existential threat. this report, the fossil fuel industry hopes that by capitalizing on very low public As Sempra Energy, the parent company awareness of the respective cost, supply, for California utilities SoCalGas and San and sustainability challenges that exist for Diego Gas & Electric Company (“SDG&E”) broad-scale use of FGAs, they can sell them noted in its annual 10-K Report, increased as an alternative to building electrification. use of renewable energy and electrification “could have a material adverse effect on This section lays out how building SDG&E’s, SoCalGas’ and Sempra Energy’s electrification challenges the gas industry’s cash flows, financial condition and results of business model and profits, and how FGAs operations.”42 rose to prominence within their efforts and tactics to fight electrification. Indeed, in a 2014 presentation to senior management, SoCalGas already foresaw Like electric utilities, gas utilities profit not the risks of electrification to its business, by selling the gas itself, but by maintaining fighting against higher proposed efficiency infrastructure that delivers energy to homes standards for in new and businesses within an exclusive construction to block the pathway toward territory. Their businesses are regulated by highly efficient electric water state commissions, which allow heating and more widespread building them to earn a rate of return on the money electrification. they invest in their gas pipeline networks. While investors have typically prized gas On average, gas utilities generate more utilities, valuing them higher than their than 85% of their gross revenues38 from electric counterparts for many years, signs their residential and commercial customers. are emerging that investor confidence in In the last 20 years, gas utilities have added the future of gas may be in question.43 This 12.4 million new residential customers,39 has also been visible on recent gas utility and spent more than $22 billion annually40 quarterly earnings calls, where company replacing old pipes, averaging a 12% per executives are increasingly being forced to year increase in capital investment from defend the sustainability of their businesses 2010 to 2016.41 About 30% of the nation’s to the financial community.44 residential and commercial gas demand is delivered by gas-only utilities, as Gas interests are under pressure to both opposed to those who deliver both gas and demonstrate they are taking steps to reduce electricity, making these organizations that emissions while also illustrating alternative much more dependent on maintaining the pathways that allow gas infrastructure to status quo. continue being “used and useful” and also expanded. Any large-scale shift that reduces gas usage, such as electrification, poses an

18 EarthjusticeEarthjustice & & Sierra Sierra Club Club | | Rhetoric Rhetoric vs. vs. Reality Reality

In a 2014 presentation to senior management, SoCalGas already foresaw the risks of electrification to its business, fighting against higher proposed efficiency standards for water heating in new construction to block the pathway toward highly efficient electric heat pump water heating and more widespread building electrification.

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How the gas industry seeks 2. to short-circuit building electrification

The movement towards all-electric buildings, which emerged in 2019 with a wave of measures seeking to replace gas appliances with increasingly efficient and consumer- friendly electric alternatives, poses a new long-term financial threat to the gas industry.

To date, more than 30 communities in California and have passed policies restricting or eliminating the installation of any new gas infrastructure in new buildings, or promoting all-electric building codes. These communities include San Jose, California, the tenth largest in the U.S., and Brookline, Massachusetts,45 which became the first local government on the East Coast to adopt its own electrification policy. Dozens of other cities across the country are considering similar measures.

States, too, are beginning to examine how to wind down investment in existing gas distribution networks. California,46 New Jersey,47 and New York48 in particular are updating and modernizing planning processes, gearing them towards a clean Residents Line Up to Speak in Support of Berkeley’s energy future that reduces or eliminates the All-Electric Building Code need for future gas infrastructure investment.

The gas industry quickly mobilized against pro-electrification legislation,49 using front groups to wage aggressive misinformation campaigns. Prominent examples include:

• SoCalGas set up and continues to fund Californians for Balanced Energy Solutions (“C4BES”), a front group masquerading as a grassroots organization.50 A filing to the California Public Utilities Commission shows how SoCalGas hired a PR firm to set up and provide ongoing support to this organization.51 • The Seattle Times recently exposed a $1 million effort from Washington and Oregon gas companies to form a new group dubbed the Partners for Energy Progress, which launched in May 2020.52 It is intended to represent a coalition of unions, businesses, and consumer groups specifically to help “prevent or defeat” local electrification initiatives. They received advice from C4BES.

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• Hawaii Gas, facing a Honolulu City would limit or ban the inclusion of gas Council bill that would limit gas water infrastructure in new buildings. heaters in newly built homes, hired legislators, at the behest of the utility a Seattle-based political consulting Southwest Gas,56 passed the first such firm to create a new front group measure, soon followed by Tennessee,57 called Our Energy Choice and fund the second state to enact such a law. additional opposition campaigns.53 Similar bills forbidding gas bans, using near • Before the town of Brookline identical language to the Arizona bill, have passed a measure to prohibit new been introduced in Kansas,58 Minnesota,59 fossil fuel infrastructure in major Mississippi,60 ,61 and .62 construction projects, a group called SoCalGas also advocated for a similar law the Massachusetts Coalition for in California. In an email to C4BES Board unsuccessfully Members, the Vice President for External pressed Brookline officials to reject Affairs and Environmental Strategy at the policy.54 Despite its name, SoCalGas stated “Regarding the AZ bill, however, this organization is actually maybe we at C4BES should be looking at an Astroturf front group formed to that approach here in CA.” promote gas pipeline expansion projects and funded by in-state These efforts to stymie building gas interests and utilities including electrification are effectively kneecapping , Eversource, and National local governments that are serious about Grid.55 meeting their long-term emissions reductions goals, since this sector represents such Recently, gas interests have also turned to a significant portion of citywide carbon a preemption strategy. Industry allies have emissions. Building emissions represent 27% begun pushing bills in state legislatures of the footprint in Berkeley, that would preempt or prevent cities and California,63 nearly two-thirds in Brookline,64 towns from enacting local ordinances that and as high as 73% in Washington, D.C.65

Community Demonstration at SoCalGas/C4BES Press Conference in Riverside, CA 2121 Earthjustice & Sierra Club | Rhetoric vs. Reality

Industry claims about 3. fossil gas alternatives

The gas industry’s strategy to prevent electrification by locking in FGAs is framed as a pursuit of a more sustainable future. The pitch consists of oft- repeated statements meant to confuse the public over the value and cost of electric alternatives while promoting FGAs.

At least 10 op-eds from gas industry surrogates, promoting misleading data on the costs related to electrification while pushing FGAs as a better solution, have been published in California and national media between late 2018 and 2020.

Local utilities, eager to continue supplying gas to homes and buildings and provide some justification for their role in a decarbonized future, have been particularly aggressive in pushing and inflating the potential of FGAs.

SOUTHERN CALIFORNIA GAS COMPANY

In March 2019, SoCalGas announced its intent to become the “cleanest natural gas utility in North America.” A cornerstone of that strategy is to replace 20% of its fossil gas supply with FGAs by 2030:

“Research shows that replacing about 20% of California’s traditional natural gas supply with would lower emissions equal to retrofitting every building in the state to run on electric-only energy and at a fraction of the cost,” a company press release claims. “Using renewable natural gas in buildings can be two to three times less expensive than any all-electric strategy and does not require families or businesses to purchase new appliances or take on costly construction projects.”66

As illustrated in Part 1 of this report, the reality is that FGAs can take California only marginally down the path of reducing emissions, and at an extremely high cost, while building electrification can cost-effectively take it to zero. The California Energy Commission, across two reports and three years, has found building electrification is the cheapest and lowest-risk option to decarbonize the state’s buildings. SoCalGas’s claims and rhetoric run counter to all reputable analyses on the topic, and SoCalGas has been silent on how much replacing 20% of its gas with FGAs would cost its customers.

Emails show that SoCalGas’s front group, C4BES, was set up specifically to help spread this inaccurate message. In a welcome letter between Ken Chawkins, a SoCalGas employee, and Matt Rahn, who was recruited by SoCalGas as the chair of the board of C4BES, Chawkins states the purpose of C4BES: “We (C4BES) will tell the public and the media about the importance of natural and renewable natural gas.”67

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DOMINION ENERGY

Dominion Energy, a mixed-fuel utility that supplies gas to seven states, has been actively promoting FGAs as part of its pathway to decarbonization. Dominion announced68 a goal in February 2020 to reach net-zero emissions by 2050 and plans to meet that goal with FGAs, saying in their statement that capturing the methane from will offset “any remaining methane and carbon dioxide emissions from the company’s natural gas operations.”

Dominion’s RNG strategy includes a recently announced $200 million investment69 with pork conglomerate Smithfield to produce biomethane.

According to their website as of March 26, 2020, “Our goal is to meet 4 percent of our gas utility customers’ needs with RNG by 2040. Because RNG captures 25 times more greenhouse gas than it releases, that will offset our customers’ carbon footprint by 100 percent!”70

The current version of their website makes the following claim:

“[D]id you know renewable energy can also come from our nation’s farms? That’s right. Thanks to technological , we can capture waste methane from hog and dairy farms and convert it into clean energy that can heat homes and power businesses.

It’s called renewable natural gas, or RNG, and it’s transforming the future of clean energy. When methane is converted into RNG, it captures 25 times more greenhouse gases from the atmosphere than are released when RNG is used by consumers. That makes RNG better than zero-carbon. It’s actually carbon-beneficial!”71

The claim that RNG captures 25 times more greenhouse gases is unsupported, and specious at best. As explained in Part 1, sources of FGAs vary in their carbon intensity. The vast majority of FGAs are not carbon negative, and most, like , are not even carbon neutral. Even those FGAs which are sometimes considered “carbon negative,” like biomethane from manure, that consideration is based on the presumption these emissions are inevitable, in contradiction to alternative management systems which avoid emissions altogether.

No utility has thus far been forthcoming about the costs of FGAs as an alternative to building electrification, though regulators have been clear. The Minnesota Attorney General’s office called the cost of FGAs “unreasonably high”72 and noted that if a customer used that fuel exclusively, their gas bill would increase by thousands of dollars annually.

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Despite what it’s telling customers, 4. the gas industry knows the shortfalls of fossil gas alternatives

Despite these public statements, many in the role FGAs can play in “decarbonizing” the gas industry are all too aware of the the gas system, internal documents show problems with wide-scale promotion and there were and are concerns about the production of FGAs. Internal documents and costs and supply of these fuels. communications illustrate how and when the strategy of using FGAs as a defense against In a document obtained by the Climate building electrification emerged, as well as Investigations Center,75 Mark Krebs, an the cost and feasibility issues around these specialist at St. Louis-based fuels. Spire Energy, wrote to other gas utility employees, “If CA sees builders use more The American Gas Association’s Clean gas, they will probably clamp down on it; Energy Task Force developed draft policy unless it is RNG; hence all the hoopla over principles for FGAs in January 2018. RNG. In my opinion, RNG will not sustain our As stated in the document,73 the AGA industry at its present size.” “supports policies that define the term ‘renewable energy’ to include RNG on par Even members of the board of C4BES – the with other energy sources, such as energy pro-gas industry front group developed and generated from wind or solar resources.” funded by SoCalGas – expressed concerns The principles also discuss FGAs as a way about the misleading characterization of for gas to count towards Zero Net Energy FGAs. Michael Boccadoro, a lobbyist for standards for buildings. California’s dairy industry, which stands to benefit from incentives promoting the An internal set of AGA meeting notes from production of FGAs from large dairies, sat March 2018 shows the industry’s interest on the board of C4BES at its launch. He in using FGAs to “mitigate the opposition’s told The Guardian, “Dairy biogas is way too fervor.” After FGAs “piqued the interest expensive” to use in home or businesses – of opposition group” Mothers Out Front, five to 10 times more expensive than fossil a Boston-based nonprofit dedicated to gas. phasing out fossil fuels, the group reached out to National Grid, a gas utility that He also stated, “It doesn’t pencil out and operates in Massachusetts, to learn more it doesn’t make all that much sense from about the fuel. The meeting notes record an environmental standpoint. It’s a pipe the following action item in response: dream.”76 “Consider how technologies to decarbonize the pipeline can serve as a conduit to Boccadoro raised his concerns about supply environmental organizations, thereby and price in emails with the rest of the seeking to mitigate the opposition’s fervor C4BES board, which were played down by against infrastructure expansion.”74 the chairman, Matt Rahn. Boccadoro left the board shortly thereafter. ■ At the same time as the industry quickly began to outwardly express confidence in

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CONCLUSION: Benefits of building electrification should not be obscured by a fog of gas industry misinformation

The continued evolution of our energy systems and the push towards net-zero emissions require honest accounting of the pros and cons of different energy solutions. State agencies and independent analysis have overwhelmingly concluded that powering the grid with renewable energy and electrifying buildings is one of the quickest, most cost-effective ways to hit emission reduction goals.

Closer scrutiny of the production and distribution challenges of fossil gas alternatives (called “renewable natural gas” by the gas industry) are not, and are unlikely to ever be, a substitute for widespread electrification. Their role, if any, should be specialized and limited to specific industries that can’t easily electrify, specifically and air or maritime transport. If focused on those specific functions, these fuels can play a potential role in complementing the society-wide .

The gas industry’s well-documented campaign of skewing facts, misleading consumers, and branding fossil gas alternatives as a renewable, sustainable energy source must be recognized for what it is: a PR campaign to protect the industry’s financial interests and preserve a business model that is incompatible with achieving a net-zero emissions society. The movement towards building electrification is gaining ground in the United States on a local level because it’s the most viable and affordable option for reducing emissions from the built environment. A straightforward reading of the facts and the adoption of existing technology can steer policymakers, consumers, and utilities alike towards a future of cleaner energy. ■

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ENDNOTES 1. Energy & Climate Staff, Preliminary US Emissions Estimates for 2018, Rhodium Group (Jan. 8, 2019), https://rhg.com/ research/preliminary-us-emissions-estimates-for-2018. 2. UCLA Fielding School of Public Health, Effects of Residential Gas Appliances on Indoor and Outdoor Air Quality and Public Health in California (Apr. 2020), https://ucla.app.box.com/s/xyzt8jc1ixnetiv0269qe704wu0ihif7; Brady Seals and Andee Krasner, Gas Stoves: Health and Air Quality Impacts and Solutions, Rocky Mountain Institute (2020), https://rmi.org/insight/gas-stoves-pollution-health/. 3. AGA, CETF Meeting February 2018: RNG Draft Policy Principles, at 11–13 (Feb. 8, 2018) (“AGA CETF Meeting February 2018”), https://www.documentcloud.org/documents/6772341-CETF-Meeting-Febuary-2018.html. 4. AGA, AGA Spring 2018 SGC Meeting at 108 (Mar. 2018), https://www.documentcloud.org/documents/6772294-AGA- Spring-2018-SGC-Meeting.html#document/p108/a549422. 5. AGA, APGA Basecamp 2018, at 615 (2018), https://www.documentcloud.org/documents/6768592-APGA- Basecamp-2018.html#document/p615/a549439. 6. Susie Cagle, US gas utility funds ‘front’ consumer group to fight natural gas bans, The Guardian (July 26, 2019), https://www.theguardian.com/us-news/2019/jul/26/us-natural-gas-ban-socalgas-berkeley. 7. Intergovernmental Panel on Climate Change (“IPCC”), Summary for Policymakers (2018), https://www.ipcc.ch/site/ assets/uploads/sites/2/2019/05/SR15_SPM_version_report_LR.pdf. 8. D. Tong et al., Committed emissions from existing energy infrastructure jeopardize 1.5 °C climate target, 572 373 (2019), https://www.nature.com/articles/s41586-019-1364-3. 9. Lorne Stockman, Burning the Gas ‘Bridge Fuel’ Myth: Why Gas is Not Clean, Cheap, or Necessary, Oil Change International, at 6 (May, 2019), http://priceofoil.org/content/uploads/2019/05/gasBridgeMyth_web-FINAL.pdf. 10. Christopher McGlade and Paul Elkins, The geographical distribution of fossil fuels unused when limiting global warming to 2°C, 517 Nature 187, 187–190 (Jan. 7, 2015), https://www.nature.com/articles/nature14016. 11. The IPCC recently revised upward the radiative force of methane, counting its warming effect as 87 times that of

CO2 over 20 years, or 36 times CO2 over 100 years. 12. Ramon A. Alvarez et al., Assessment of Methane Emissions from the U.S. Oil and Gas Supply Chain, 361 Science 186, 186–188 (July 13, 2018), https://science.sciencemag.org/content/361/6398/186. 13. Genevieve et al., Large Fugitive Methane Emissions From Urban Centers Along the U.S. East Coast, 46 Geophysical Research Letters 8500, 8500–8507 (July 15, 2019), https://agupubs.onlinelibrary.wiley.com/doi/ full/10.1029/2019GL082635. 14. Marc L. Fischer et al., An Estimate of Natural Gas Methane Emissions from California Homes, 52 Envtl. Sci. Tech. 10205, 10205–10213 (Aug. 2, 2018). 15. National Renewable Energy Laboratory, Energy Analysis: Biogas Potential in the United States (Oct. 2013), https:// www.nrel.gov/docs/fy14osti/60178.pdf. 16. Agora and Agora Verkehrswende, The Future Cost of Electricity-Based Synthetic Fuels, at 14 (Sept. 19, 2018), https://www.agora-energiewende.de/fileadmin2/Projekte/2017/SynKost_2050/Agora_SynKost_Study_EN_ WEB.pdf. 17. Natural Resources Defense Council, A Pipe Dream or Climate Solution? The Opportunities and Limits of Biogas and Synthetic Gas to Replace Fossil Gas (June 2020), https://www.nrdc.org/sites/default/files/pipe-dream-climate- solution-bio-synthetic-gas-ib.pdf. 18. Emily Grubert, At Scale, Renewable Natural Gas Systems Could be Climate Intensive: The Influence of Methane Feedstock and Leakage Rates, Envtl. Research Letters (2020) (in press), https://doi.org/10.1088/1748-9326/ab9335. 19. Id. at 6. 20. Id. at 2. 21. Id. at 7. 22. Id. at 7. 23. AGF, Renewable Sources of Natural Gas: Supply and Emissions Reduction Assessment (Dec. 2019), https://www. gasfoundation.org/wp-content/uploads/2019/12/AGF-2019-RNG-Study-Executive-Summary-Final-12-18-2019-AS-1. pdf. The AGF Study estimates total resource potential in 2040 to be between 1,660 tBtu (low scenario) and 3,780 tBtu (high scenario). According to the U.S. Energy Information Administration (“U.S. EIA”), total US Gas Consumption in 2018 equals 30,075 tBtu. U.S. EIA, Natural Gas Explained, https://www.eia.gov/energyexplained/natural-gas/use- of-natural-gas.php (last visited May 29, 2020). FGA resource potential therefore ranges from 6% (1,660 tBtu / 30,075 tBtu) to 13% (3,780 tBtu / 30,075 tBtu). 24. U.S. EPA, Biofuels and the Environment: The Second Triennial Report to Congress, at 37 (June 29, 2018), https:// cfpub.epa.gov/si/si_public_record_report.cfm?Lab=IO&dirEntryId=341491 25. U.S. EIA, Henry Hub Natural Gas Spot Price, https://www.eia.gov/dnav/ng/hist/rngwhhdD.htm (last visited May 28, 2020).

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26. AGF, Renewable Sources of Natural Gas: Supply and Emissions Reduction Assessment, at 51 (Dec. 2019), https:// gasfoundation.org/wp-content/uploads/2019/12/AGF-2019-RNG-Study-Full-Report-FINAL-12-18-19.pdf. 27. See, e.g., California Energy Commission, The Challenge of Gas in California’s Low-Carbon Future (Apr. 2020), https://ww2.energy.ca.gov/2019publications/CEC-500-2019-055/CEC-500-2019-055-F.pdf. 28. Id. at 4. 29. Id. at 24. 30. Id. at 4. 31. National Renewable Energy Laboratory, California Power-to-Gas and Power-to-Hydrogen Near-Term Business Case Evaluation, at 37 (Dec. 2016), https://www.nrel.gov/docs/fy17osti/67384.pdf. 32. Agora Energiewende and Agora Verkehrswende, The Future Cost of Electricity-Based Synthetic Fuels, at 11 (Sept. 19, 2018), https://www.agora-energiewende.de/fileadmin2/Projekte/2017/SynKost_2050/Agora_SynKost_Study_EN_ WEB.pdf. 33. Id. at 14. 34. Id. 35. Evolved Energy Research, New Jersey 2019 IEP Technical Appendix (Nov. 29, 2019), https://nj.gov/emp/pdf/New_ Jersey_2019_IEP_Technical_Appendix.pdf. 36. California Energy Commission, Air Quality Implications of Using Biogas to Replace Natural Gas in California (May 2020), https://ww2.energy.ca.gov/2020publications/CEC-500-2020-034/CEC-500-2020-034.pdf. 37. UCLA Fielding School of Public Health, Effects of Residential Gas Appliances on Indoor and Outdoor Air Quality and Public Health in California, at 18 (Apr. 2020), https://ucla.app.box.com/s/xyzt8jc1ixnetiv0269qe704wu0ihif7. 38. AGA, Gas Industry Revenues From Sales by Class of Service 1996–2018, https://www.aga.org/ contentassets/95bfd59fd72048baa030f00d08094592/table7-1.pdf (last visited May 28, 2020). 39. AGA, Natural Gas, Our Clean Energy Future: 2020 Playbook, http://playbook.aga.org (last visited May 28, 2020). 40. AGA, Get the Facts: Pipeline Safety (2019), https://www.aga.org/ contentassets/7e9157649d70496391b38baff62506ed/pipeline-safety_final.pdf. 41. Adam Barth et al., Are US gas utilities nearing the end of their golden age?, McKinsey & Co. (Sept. 20, 2018), https:// www.mckinsey.com/industries/electric-power-and-natural-gas/our-insights/are-us-gas-utilities-nearing-the-end-of- their-golden-age. 42. Sempra Energy, SoCalGas and SDG&E, Form 10-K Annual Report at 45 (Feb. 27, 2020), https://investor.sempra.com/ static-files/68af0350-d99c-412c-af4f-aa8e6c8e2606. 43. Gerson Freitas Jr. and Vanessa Dezem, Wall Street Is Falling Out of Love With a Once-Coveted Fossil Fuel, Bloomberg (Mar. 3, 2020), https://www.bloomberg.com/news/articles/2020-03-03/wall-street-is-falling-out-of-love- with-a-once-coveted-fossil-fuel. 44. Tom DiChristopher, Utility CEOs embrace role as natural gas defenders on earnings calls, S&P Global Market Intelligence (Mar. 6, 2020), https://www.spglobal.com/marketintelligence/en/news-insights/latest-news-headlines/ utility-ceos-embrace-role-as-natural-gas-defenders-on-earnings-calls-57446738. 45. Jon Chesto, Brookline’s ban on natural gas connections spurs other municipalities to consider the idea, Boston Globe (Dec. 11, 2019), https://www.bostonglobe.com/business/2019/12/11/after-brookline-other-cities-and-towns-start- consider-their-own-natural-gas-bans/BRKynpIlfOs4miQlDKIkIK. 46. Kavya Balaraman, California launches rulemaking to manage transition away from natural gas, Utility Dive (Jan. 17, 2020), https://www.utilitydive.com/news/cpuc-launches-rulemaking-transition-natural-gas/570653/. 47. New Jersey Board of Public Utilities et al., 2019 New Jersey Energy Master Plan: Pathway to 2050, https://nj.gov/ emp/docs/pdf/2020_NJBPU_EMP.pdf (last visited May 28, 2020). 48. Tom DiChristopher, In bid to cut gas use, pipe investment, NY regulator to overhaul energy policy, S&P Global Market Intelligence (Mar. 20, 2020), https://www.spglobal.com/marketintelligence/en/news-insights/latest-news- headlines/in-bid-to-cut-gas-use-pipe-investment-ny-regulator-to-overhaul-energy-policy-57696460. 49. Tom DiChristopher, AGA takes steps to counter gas bans, state opposition to pipelines, S&P Global Market Intelligence (Jan. 17, 2020), https://www.spglobal.com/marketintelligence/en/news-insights/latest-news- headlines/56763558. 50. Michael Hiltzik, Column: SoCal Gas accused of setting up an ‘astro-turf’ group to plead its case to regulators, Los Angeles Times (Aug. 8, 2019), https://www.latimes.com/business/story/2019-08-07/socal-gas-astroturf-group- allegations; Michael Hiltzik, Column: An Alleged SoCalGas front group withdraws from a PUC proceeding — but questions remain, Los Angeles Times (Aug. 21, 2019), https://www.latimes.com/business/story/2019-08-21/ californians-for-balanced-energy-solutions-socal-gas-puc. 51. California Public Utility Commission (“CPUC”), Rulemaking (“R.”) 19-01-011, Response of the Public Advocates Office to SoCalGas’ Motion to Strike Sierra Club’s Reply to Responses to Motion to Deny Party Status to Californians for Balanced Energy Solutions or, in the Alternative to Grant Motion to Compel Discovery (July 5, 2019), https:// earthjustice.org/sites/default/files/files/PAO-Response-to-SoCalGas-Motion-to-Strike.pdf. 52. Hal Bernton and Daniel Beekman, Natural gas industry’s $1 million PR campaign sets up fight over Northwest’s energy future, Seattle Times (Dec. 22, 2019), https://www.seattletimes.com/seattle-news/natural-gas-industrys-1- million-pr-campaign-sets-up-fight-over-northwests-energy-future/. 53. Stewart Yerton, How The Gas Company Plans To Fight A Bill Banning Gas Water Heaters, Honolulu Civil Beat (Dec. 9, 2019), https://www.civilbeat.org/2019/12/how-the-gas-company-plans-to-fight-a-bill-banning-gas-water-heaters/. 54. Chris D’Angelo, The Gas Industry’s Bid To Kill A Town’s Fossil Fuel Ban, The Huffington Post (Dec. 8, 2019), https:// www.huffpost.com/entry/massachusetts-natural-gas-ban_n_5de93ae2e4b0913e6f8ce07d.

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55. Itai Vardi, A New Massachusetts ‘Sustainable Energy’ Coalition Is Really A Front For Gas Interests, The Huffington Post (Feb. 22, 2018), https://www.huffpost.com/entry/natural-gas-coalition-massachusetts_n_5a8f2563e4b0528232 aa904e. 56. Elizabeth Whitman, Arizona Bill That Would Ban Local Gas Bans Lands on Governor Ducey’s Desk, Phoenix New Times (Feb. 19, 2020), https://www.phoenixnewtimes.com/news/arizona-natural-gas-preemption-southwest-gas- ducey-utilities-11445592. 57. Tom DiChristopher, Gas Ban Monitor: California clears coronavirus hurdles; . strategy splinters, S&P Global Market Intelligence (Apr. 6, 2020), https://www.spglobal.com/marketintelligence/en/news-insights/latest-news- headlines/gas-ban-monitor-california-clears-coronavirus-hurdles-mass-strategy-splinters-57926053. 58. House Bill (“HB”) 2703 (2020), http://www.kslegislature.org/li/b2019_20/measures/hb2703. 59. HF 3303 (2020), https://www.revisor.mn.gov/bills/text.php?number=HF3033&version=0&session=ls91&session_ year=2020&session_number=0. 60. Senate Bill 2685 (2020), http://billstatus.ls.state.ms.us/2020/pdf/history/SB/SB2685.xml. 61. HB 2697 (2020), https://house.mo.gov/Bill.aspx?bill=HB2697&year=2020&code=R. 62. HB 3619 (2020), http://webserver1.lsb.state.ok.us/cf_pdf/2019-20%20COMMITTEE%20AMENDMENTS/House/ HB3619%20FULLPCS1%20TERRY%20ODONNELL-AMM.PDF. 63. Office of City Manager, Climate Action Plan Update (Dec. 6, 2018), https://www.cityofberkeley.info/Clerk/City_ Council/2018/12_Dec/Documents/2018-12-06_WS_Item_01_Climate_Action_Plan_Update_pdf.aspx. 64. Town of Brookline, Massachusetts Overview (May 21, 2010), https://www.brooklinema. gov/ArchiveCenter/ViewFile/Item/628. 65. Department of Energy & Environment, Greenhouse Gas Inventories, https://doee.dc.gov/service/greenhouse-gas- inventories (last visited May 28, 2020). 66. SoCalGas, SoCalGas Announces Vision to be Cleanest Natural Gas Utility in North America, PR Newswire (Mar. 6, 2019), https://www.prnewswire.com/news-releases/socalgas-announces-vision-to-be-cleanest-natural-gas-utility-in- north-america-300807922.html. 67. CPUC, R.19-01-011, Sierra Club’s Mot. to Deny Party Status to [C4BES] or, in the Alternative, to Grant Mot. to Compel Disc., Attach. D (May 14, 2019), https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M292/K932/292932611.PDF. 68. Dominion Energy, Dominion Energy Sets New Goal of Net Zero Emissions by 2050 (Feb. 11, 2020), https://news. dominionenergy.com/2020-02-11-Dominion-Energy-Sets-New-Goal-of-Net-Zero-Emissions-by-2050. 69. Catherine Morehouse, Dominion extends poop power push with $200M Vanguard Renewables partnership, Utility Dive (Dec. 13, 2019), https://www.utilitydive.com/news/dominion-extends-poop-power-200m-vanguard-renewables- RNG-farms-natural-gas/569004/. 70. Dominion Energy, Renewable Natural Gas (Mar. 26, 2020), https://web.archive.org/web/20200326001324/https:// www.dominionenergy.com/company/renewable-natural-gas. 71. Dominion Energy, Renewable Natural Gas: Turning Waste into Clean Energy, https://www.dominionenergy.com/ company/renewable-natural-gas (last visited May 28, 2020). 72. Frank Jossi, Minnesota utility wants to offer customers renewable natural gas option, Energy News Network (Jan. 30, 2019), https://energynews.us/2019/01/30/midwest/minnesota-utility-wants-to-offer-customers-renewable-natural- gas-option/. 73. AGA CETF Meeting February 2018 at 12. 74. Climate Investigations Center, Renewable Natural Gas (Feb. 9, 2020), https://climateinvestigations.org/renewable- natural-gas/. 75. Id. 76. Susie Cagle, US gas utility funds ‘front’ consumer group to fight natural gas bans, The Guardian (July 26, 2019), https://www.theguardian.com/us-news/2019/jul/26/us-natural-gas-ban-socalgas-berkeley.

i. Sheraz Gill et al., Air Pollution Control Officer’s Revision of the Dairy VOC Emission Factors, SJVAPCD, at 9 (Feb. 2012), https://www.valleyair.org/busind/pto/emission_factors/2012-Final-Dairy-EE-Report/FinalDairyEFReport(2-23-12).pdf. ii. Eli Moore et al., The Human Costs of Nitrate-contaminated Drinking Water in the San Joaquin Valley, Pacific Institute, at 7 (Mar. 2011), https://pacinst.org/wp-content/uploads/2011/03/nitrate_contamination3.pdf. iii. J.P. Cativiela et al., Summary Representative Monitoring Report (Revised*), CVDRMP, at 6 (Apr. 19, 2019), https://www. waterboards.ca.gov/centralvalley/water_issues/confined_animal_facilities/groundwater_monitoring/srmr_20190419.pdf. iv. U.S. EPA, Inventory of U.S. and Sinks: 1990-2017 – , at 5–9, (2019) https:// www.epa. v. gov/sites/production/files/2019-04/documents/us-ghg-inventory-2019-chapter-5-agriculture.pdf. California Climate and Agriculture Network, Diversified Strategies for Reducing Methane Emissions from Dairy Operations (Oct. 2015), http://calclimateag.org/wp-content/uploads/2015/11/Diversified-Strategies-for-Methane-in- vi. Dairies-Oct.-2015.pdf. Leadership Counsel for Justice and Accountability, A Working Paper on the CDFA Dairy Digester Research and Development Program (Apr. 2019), https://leadershipcounsel.org/wp-content/uploads/2019/04/A-Working-Paper-on- GGRF-Dairy-Digester-Program.pdf.

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